RGI Position Papers

RGI regularly publishes positions with regard to current political developments and consultations. All of them can be downloaded below.

RGI Statement on the 'Do No Significant Harm' Technical Guidance under the Social Climate Fund

August 2024

The Renewables Grid Initiative (RGI) welcomes the opportunity to provide feedback to the Draft 'Do No Significant Harm' (DNSH) Technical Guidance for the Social Climate Fund (SCF).

At RGI, we strongly believe that this tool, if effectively designed and implemented, has the potential to accelerate the energy transition and scale up proven technologies that will not only bring significant benefits to end users, but also to the decarbonisation trajectory and the energy system at large. For this to happen, the application of the DNSH principle, in conjunction with further safeguards envisaged in the SCF Regulation (Regulation (EU) 2023/955 of the European Parliament and of the Council) and applicable EU law, should follow a robust, holistic and forward-looking approach.

The full Statement can be downloaded by clicking here.


RGI Statement on Renewables Acceleration Areas

February 2024

The Renewables Grid Initiative (RGI) welcomes the opportunity to provide feedback to the call for evidence with regard to the upcoming guidance on designating renewable acceleration areas.

It is acknowledged that, if well designed, the renewable acceleration areas can be valuable tools towards the swift development of variable renewable energy sources (RES) in the European Union. A balanced approach can increase predictability and certainty for new investments. However, renewables acceleration areas represent a make-or-break opportunity rather than offering a blank check. They demand careful consideration. They should also not become tools to fuel public opposition. Instead, Member States should adopt a holistic approach towards processes and solutions, encompassing technical, environmental, and societal aspects.

The full Statement can be downloaded by clicking here.


RGI Statement on the Action Plan for Grids

November 2023

The Renewables Grid Initiative (RGI) welcomes the announcement of the Action Plan for Grids. To enhance the plan’s effectiveness, we propose a holistic approach and key considerations to be taken into account by the European Commission.

We strongly believe that tackling the intertwined climate, energy and biodiversity crises and ensuring independence, competitiveness and affordability necessitates the European Union to embed a holistic approach towards system planning, as well as consider biodiversity and people at the centre of the process.

The full Statement can be downloaded by clicking here.


RGI’s feedback to the EBRD Energy Sector Strategy 2024-2028

November 2023

RGI shares feedback to the draft Energy Sector Strategy 2024-2028 of the European Bank for Reconstruction and Development (EBRD). While acknowledging the efforts to draft a well-rounded strategy, RGI also calls on EBRD to pursue a holistic approach to the energy transition in line with the EU and global priorities.

RGI regrets that the proposed Strategy envisages continuous support to fossil-fuel investments. Such an approach is incompatible with the climate urgency the world is facing and the long-term objective of climate neutrality/net-zero. Moreover, it could lead to the reliance on costly and dubious in terms of effectiveness and safety technologies, such as Carbon Capture and Storage (CCS). Instead, we urge the EBRD to prioritise phasing out support and subsidies to all fossil fuels, including fossil gas, and furthermore, to raise the Strategy’s climate/energy ambition, and replace the current prioritisation of ‘low-carbon pathways’ and ‘low-carbon readiness’ of infrastructure with ‘RES pathways’.

The full Statement can be downloaded by clicking here.


OCEaN statement on the upcoming EU Wind Power Package

October 2023

In the State of the Union speech, Ursula Von der Leyen, President of the European Commission, acknowledged the unique set of challenges currently faced by the European wind industry. To address these, she announced an upcoming EU Wind Power package to support the wind industry to deliver on the EU Green Deal.

In this statement, Offshore Coalition for Energy and Nature (OCEaN) Members pledge to assist EU institutions and Member States in identifying ecological minimum requirements and non-price evaluation criteria and serve as a knowledge hub for best practices and scientific evidence.

The full Statement can be downloaded by clicking here.


RGI’s statement on the functioning of the Governance Regulation of the Energy Union and Climate Action

August 2023

RGI responds to the Governance Regulation consultation, urging for a holistic approach that takes into account cross-sector linkages, meaningful stakeholder engagement, transparent data, nature protection and societal involvement, while allowing for direct electrification, and monitoring progress through short and long-term frameworks within each national context.

RGI strongly believes that the Governance Regulation should aim at up to date, robust, timely, transparent and high-quality planning, reporting and monitoring with clear and ambitious short-term (National Energy and Climate Plans) and long-term (national Long-Term Strategies) decarbonisation commitments, that cumulatively achieve the targets and objectives of the European Union (EU). This necessitates plans and strategies to be strengthened in terms of effectiveness and include clarity about timeframes for implementability and enabling schemes, as well as enforcement measures at the EU level.

The full Statement can be downloaded by clicking here.


The European Commission, ACER and RGI publish statement on high-quality regular stakeholder engagement in energy infrastructure

June 2023

Together with the European Commission and the EU Agency for the Cooperation of Energy Regulators (ACER), RGI argues for meaningful, continuous stakeholder engagement in order to account for and minimise the impacts building large infrastructure has on communities and nature. The scale and speed of energy infrastructure needed to reach Europe’s ambitious clean energy targets requires meaningful stakeholder engagement to be reinforced. But what high-quality regular stakeholder engagement means? And how should we implement it?

Read the full statement here to learn more.


RGI’s statement on the EU 2040 climate target

June 2023

RGI welcomes the opportunity to contribute to the development of an EU climate target for 2040 and calls for a holistic approach in our Statement. RGI strongly believes that the EU 2040 climate target should be consistent with the Paris Agreement and aligned with the greenhouse gas (GHG) budget. To achieve this, the target setting should be science-based and consider the latest scientific evidence, such as the latest reports of the European Scientific Advisory Board on Climate Change (ESABCC) and IPCC. Such an approach will increase the credibility of the upcoming proposal and set a good example for other regions around the globe as well as urge and incentivise the achievement of the 2030 climate target. The upcoming proposal should recognise the crucial role of electricity grids, both at the transmission and distribution levels and follow a robust assessment of the impacts on nature and societies

The full Statement can be downloaded by clicking here.


RGI Statement on the EU Electricity Market Design reform

May 2023

A future-proof electricity market design requires a strong vision focusing on electrification and decarbonisation by 2040. With this statement, Renewables Grid Initiative (RGI) and its Members want to concentrate on a few aspects of the European Commission’s legislative proposal on the reform of the EU electricity market design and make proposals as well as raise questions which will guide policymakers through the ongoing and upcoming legislative processes.

The full Statement can be downloaded by clicking here.


OCEaN Statement on ecological criteria in offshore wind farm auctions

April 2023

Reconciliation between renewable energy infrastructure and nature is not only possible, but also needed in order to promote a sustainable energy transition. Including non-price ecological criteria within offshore wind auctioning processes is an opportunity to develop solutions which can provide benefits for nature and the climate, which is at the core of OCEaN’s objectives. OCEaN therefore encourages European Member States to make full use of ecological non-price criteria for the design of offshore wind farm auctions in this Statement.

The full Statement can be downloaded by clicking here.


RGI statement on the REPowerEU chapters in the recovery and resilience plans

December 2022

RGI acknowledges that significant public and private investments are needed to bridge the investment gap for the energy transition, while maintaining energy security and security of supply. However, the proposal to amend the Recovery and Resilience Facility in the context of the REPowerEU, and the positions of the European Parliament and Council raise concerns about the effectiveness of the proposed measures. In our statement, we therefore call for the co-legislators to adopt a holistic approach when addressing the current energy crisis without undermining European climate, energy and nature protection ambitions.

The full Statement can be downloaded by clicking here.


OCEaN Statement on an Improved, Robust and Timely MSP Process

October 2022

The Members of the Offshore Coalition for Energy and Nature (OCEaN) strongly support an improved, robust and timely Maritime Spatial Planning (MSP) process. This will speed up ORE, support the decision-making process for spatial allocation, and also reduce investment risks and project delays. In this context, OCEaN recommends in this Statement a number of principles to be considered by all EU Member States, including: improving application of an ecosystem-based approach in MSP, complementing environmental and socio-economic assessments for spatialdesignation with sensitivity mapping, enabling cross-border collaboration, continuing to implement EU nature law to a high standard; improving stakeholder involvement and creating benefits for local communities; and, adopting a long-term perspective.

The full Statement can be downloaded by clicking here.


RGI Statement on Renewable Hydrogen

June 2022

RGI calls for a robust assessment of renewable hydrogen production and use and strongly believes that direct electrification should always take precedence, while renewable hydrogen could play a role in some hard-to-abate applications and for long-term storage purposes.

RGI also acknowledges that scarcity is becoming the new normal. Planning renewable hydrogen production, as well as other alternative technological applications, should therefore be done with resources and space availability in mind.

The full Statement can be downloaded by clicking here.


OCEaN Statement on the upcoming EU Restoration Law

June 2022

Nature restoration and the energy transition must be planned and implemented hand-in- hand so they can jointly support each other in delivering the EU’s climate and energy goals. Therefore, NGOs, wind industry, and Transmission System Operators (TSOs), working collaboratively in the Offshore Coalition for Energy and Nature (OCEaN), call for a strong EU Restoration Law with clear and quantifiable legally binding targets, as well as implementation and enforcement rules that enable ecologically-sound offshore wind and electricity deployment.

The full Statement can be downloaded by clicking here.


RGI Reaction to the REPowerEU Action Plan

May 2022

In May 2022, RGI released a reaction to the REPowerEU Action Plan, emphasing that speeding up infrastructure deployment for developing and integrating renewables needs to be connected to nature and biodiversity restoration

Within the current geopolitical changes and to achieve or surpass our climate and energy targets, we need to prioritise and streamline processes for wind and solar infrastructure development as well as the necessary electricity grids. However, it is imperative that the effort of speeding up infrastructure deployment for developing and integrating renewables is connected to nature and biodiversity restoration. This means that REPowerEU and the definition of ‘renewables go-to areas’ need to be very strongly linked to the upcoming EU Nature Restoration Targets and the activities required to achieve both objectives need to be planned coherently and jointly.

The full Reaction can be downloaded by clicking here.


RGI calls for balanced approach on inclusion of Lead in Authorisation List under REACH Regulation

April 2022

RGI calls for balanced approach on inclusion of Lead in Authorisation List under REACH Regulation due to its needed use in electricity subsea cables.

RGI recognises that enhanced research and development is needed prior to any decision that could affect domestic production and availability of internally Lead-sheathed cables. For this to happen, adequate time should be made available for the European cabling industry to find technical and commercial alternatives, ultimately resulting in the replacement of Lead with other feasible alternatives.

The full Statement can be downloaded by clicking here.


RGI position on the 'Fit for 55' package

July 2021

On 14th July, the European Commission tabled a part of the ‘Fit for 55‘ package to strengthen the EU Emissions Trading System, update the Energy Taxation Directive, and propose new CO2 standards for cars, new energy efficiency standards for buildings, new targets for renewables, and new ways of supporting clean fuels and infrastructure for clean transport.

This is one of the most ambitious policy overhauls in EU history and a unique opportunity for the EU to set the foundations for an at least 55% GHG reduction by 2030 and climate neutrality by 2050.

RGI strongly believes that a renewable-based electrification of our economy, coupled with the sustainable expansion and modernisation of EU electricity grid, is the fastest and most cost-effective way to achieve significant CO2 emission reductions over the coming decade. Therefore, we recommend for the messages in our position paper to be considered in the revision.

The full Position Paper can be downloaded by clicking here.


Response to the revised TEN-E Regulation

March 2021

The TEN-E (Trans-European Networks for Energy policy) is a central instrument in terms of energy infrastructure and therefore the cost-effective decarbonisation of the energy system and climate neutrality. In 2020, the EC started a revision and consultation process (to which RGI  also responded) and published a proposal in December.

RGI welcomed the overall intention of the proposal to align the network infrastructure with climate targets. However, along with our TSO and NGO Members, we have identified key principles and actions which we believe should be taken into consideration in the development of the energy infrastructure. Find the response here.


Request to Adapt European Energy Planning Scenarios

October 2020

The ‘Request to Adapt European Energy Planning Scenarios’ is a clear statement to policymakers that energy planning should work with scenarios that are compatible with the Paris Agreement, the priorities of the European Green Deal and the European Council's decision to achieve climate neutrality by 2050.

As of October 2020, 50 signatories from across society, including many transmission system operators, have signed the Request and added their names to the growing call.

The full Request can be downloaded by clicking here.


RGI position on increased EU greenhouse gas emission targets

October 2020

The Renewables Grid Initiative (RGI) strongly supports an increase of the greenhouse gas (GHG) emission reduction target as an important stepping-stone towards a 2050 climate neutrality goal.

RGI's full position paper, including specific policy recommendations, can be accessed in PDF form by clicking here.


RGI response to European Commission consultation on the Offshore Renewable Energy Strategy

September 2020

In our response to the Offshore Renewable Energy Strategy consultation, we ask that a holistic energy system approach be adopted for offshore planning expansion. Our is based on our the diverse experiences and knowledge of our Members, as well as RGI's engagement with marine stakeholders.

RGI's response to the consultation can be accessed in PDF form by clicking here.


RGI response to European Commission consultation on the revision of the TEN-E Regulation

July 2020

Our reponse to the European commission's consultation on the revision of the guidelines for trans-European energy infrastructure (TEN-E) regulation detail what we consider to be the priority elements to be taken into consideration in order to ensure that Europe's energy infrastructure can be planned to reflect changes in the energy landscape and prepares us for future challenges.

RGI's response to the consultation can be accessed in PDF form by clicking here.


'Request to Adapt European Energy Planning Scenarios'

30 June 2020

The signatories of this Request, are committed to the objective set by the ratified Paris Agreement to pursue efforts to limit global temperature rise to 1.5°C. They believe that energy infrastructure investment decisions play a fundamental role in reaching this target.

The signatories are therefore calling for the EU Ten Year Network Development Plan (TYNDP) 2022 to work with scenarios that are compatible with the Paris Agreement, the priorities of the European Green Deal and the European Council's decision to achieve climate neutrality by 2050 and thus are supported by a diverse group of stakeholders.


RGI responses to consultations on EU Strategies: Smart Sector Integration (SSI) and Hydrogen

June 2020

In response to the European Commission's consultation on the EU Strategy for Smart Sector Integration, RGI worked closely with our Member organisations to devise a detailed response on what lawmakers should prioritise in order to fully exploit the synergies enabled by an integrated energy system, deliver the energy transition and reach full decarbonisation as swiftly as possible. Furthermore, RGI responded to the consultation on the Roadmap for the preparation of the EU Strategy for Hydrogen, highlighting the aspects to be taken into account, such as terminology, infrastructure optimisation and collaborative planning, technological options and market regulation.

RGI's response to the SSI Strategy and our response to the Hydrogen Strategy are available in PDF form by clicking these hyperlinks.


RGI statement on "A sustainable stimulus plan around the Green Deal in the design of the European Recovery and Reconstruction Package"

April 2020

The Renewables Grid Initiative has issued a statement about the need to have the European Recovery and Reconstruction Package  coherent and aligned with agreed political objectives for decarbonisation and climate protection. The Green Deal and the White Deal are important frameworks to foster sustainability, fairness and growth.

We are calling for measures that lead to value creation for the economy, the environment, the climate and the European citizens. Having an energy and climate perspective, we make concrete suggestions on what is needed in the stimulus package with regard to investment in renewables, the necessary grid, flexibility measures in a decarbonising energy system. Moreover, we stress how investments in renewables and related infrastructure can deliver  new  jobs and local opportunities for communities and citizens.


RGI Open Letter on the TYNDP 2020 Scenarios

January 2020

In the context of the joint development and launch of the TYNDP 2020 by the European Network of Transmission System Operators for electricity and gas (ENTSO-E & ENTSOG respectively), RGI sends the following open letter to colleagues in the ENTSOs, ITRE Committee the European Commission. The letter contains our congratulations on the positive strides taken under this round of the TYNDPs and acknowledges the willingness of the ENTSOs to bring the scenarios in line with the Paris Agreement and with the objectives of the European Green Deal. However,  RGI recognises opportunities for further efforts to be made. These are contained in 5 key recommendations.


RGI Statement on the “Project of Common Interest PCI Consultation 2018 - 2019" February 2019

February 2019

RGI welcomes the efforts by the Commission to select and identify PCIs that are necessary infrastructure for achieving the European Union's climate energy policy objectives. It is very important that projects contribute to, and/or are coherent with delivering the objectives agreed upon in the Paris Agreement, are included in the final PCI list. This is essential to improve the reputation of the PCI label across the European Union and its perception amongst European citizens where the projects are the be realised.


RGI Statement on the “Consultation on the list of proposed Projects of Common Interest in energy infrastructure”

June 2017

RGI welcomes the efforts by the Commission to select PCIs that are in line with the energy and climate objectives Europe has committed to. It is very important that projects that contribute to, and/or are coherent with delivering the objectives agreed upon in the Paris Agreement are included in the final PCI list. This is essential to improve the reputation of the PCI-label across the European Union and its perception amongst European citizens where the projects are to be realised.


RGI and ENTSO-E handout: supporting regulations for the timely implementation of grid projects

June 2017

RGI and ENTSO-E jointly released this handout at the Energy Infrastructure Forum on 2 June in Copenhagen. It points out that implementing better projects with locally tailored, transparent and participatory planning, fostered by sound communication, will minimise impacts and reduce potential conflicts and risks of failure. I calls for a recovery of costs for such a stakeholder dialogue through grid tariffs. 


RGI Position on "Clean Energy for All Europeans"

May 2017

RGI welcomes the publication of the 'Clean Energy For All Europeans' package that should help the EU to make the transition to a zero carbon economy. RGI believes that the extensive set of legislative proposals from the European Commission is essential to ensure the full integration of efforts performed by Member States, businesses and other stakeholders for a successful energy transition in Europe and to empower citizens and prosumers by putting them in the  centre of the clean energy system for their benefit and an increased flexibility of the system. 


RGI Position "Electricity grids for renewables - for a safe global climate"

December 2015

RGI calls on global decision makers to commit to phase out fossil fuel emissions globally by 2050 and to move towards energy systems largely based on renewable energy, to prevent dangerous climate change.


RGI response to the European Commission Consultation on the list of proposed Projects of Common Interest

March 2015

The Renewables Grid Initiative (RGI) backs the concept of Projects of Common Interest (PCIs). This EU label should allow highly critical and needed electrical infrastructures to obtain faster permitting procedures, streamlined and improved regulatory conditions and European and potentially national financial support. These better conditions could facilitate a faster deployment of electricity networks to achieve Europe’s objectives for energy security, climate change mitigation and nature conservation.


RGI Position on the EU 2030 Framework for Climate and Energy Policies

February 2014

RGI calls on the European Council to agree in a timely manner on an ambitious and coherent set of binding targets for 2030 for (I) greenhouse gas emissions reductions, (II) energy efficiency and (III) renewable energy. The related needs for grid development and system security must be carefully considered when designing supporting mechanisms and policies.


RGI Position Paper regarding Commission Guidance for Streamlining Environmental Assessments

June 2013

The Renewables-Grid-Initiative welcomes the European Commission's work on non-binding guidance for streamlining environmental assessments of Projects of Common Interests (PCIs). Based on years of experience in balancing out different interests of TSOs and NGOs, in this position paper RGI would like to propose some complementary recommendations to the first draft of the Commission's Guidance document - on the basis of the European Grid Declaration.


RGI position regarding amendments to the proposal for a Regulation on Guidelines for Trans-­European Energy Infrastructure COM (2011) 658

May 2012

In its position paper in March 2012, RGI has suggested to further strengthen the Commission's proposal in the topics of environmental legislation, public acceptance and stakeholder involvement, and long term planning. We are pleased to see these suggestions reflected in the ITRE report.


RGI feedback on the Consultation of the ENTSO-E TYNDP 2012

April 2012

The Renewables Grid Initiative (RGI) welcomes the work that ENTSO-E has delivered in drafting the second Ten Year Network Development Plan (TYNDP) in 2012 and the invitation to give feedback on this plan in an open consultation. In view of future TYNDPs, RGI sees some room for further improvement on the process as well as the content.


RGI position on the European Commission’s Proposal for a Regulation on Guidelines for Trans-European Energy Infrastructure COM

March 2012

The Renewables Grid Initiative warmly welcomes the Commission’s current proposal for a Regulation on Guidelines for Trans-European Energy Infrastructure. RGI supports the aims to accelerate and improve the legal and administrative frameworks for grid development, but suggests to strengthen the current proposal in three areas.


Beyond Public Opposition to Grid Expansion - Achieving Public Acceptance: Transparency, Participation, Benefit Sharing

April 2011

This document presents the activities of the Renewables-Grid-Initiative and suggests practical areas of collaboration with the Commission on the issue of public acceptance. It was presented to EU Commissioner of Energy Günther Oettinger on 13 April 2011.


Submission to Infrastructure Package

October 2010

The integration of fast growing renewable electricity into the European grid and the achievement of ambitious energy security and climate protection goals of the European Union require an accelerated development of the grid network which should be reflected as a priority in the forthcoming European Infrastructure Package. In the submission, RGI proposes eight areas of intervention, which in RGI's view should be considered and included in the infrastructure package.


Note to DG Budget

July 2010

The increasing share of renewable energies in Europe’s generation mix that are required to meet Europe’s twin objectives of energy and climate security, have shown the need for expanding Europe’s current interconnectors’ capacity. This note’s purpose is to demonstrate the need for EU public (co)funding for grid infrastructure over the next 10 years that would foster the integration of large-scale and decentralised renewable energies. RGI’s position is that the purpose of public funding for grid infrastructure is to facilitate the decrease of the risk profile of such investments. Additionally, RGI stresses the urgent need of developing European harmonized regulatory conditions while developing new financing tools particularly directed at projects of European relevance and in particular at pilot projects testing new technologies.


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Funded by the European Union. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or the LIFE Programme. Neither the European Union nor the granting authority can be held responsible for them.